GAO Report Considers Small and Rural Practices’ Experiences in MIPS

The Government Accountability Office (GAO) was asked to review certain aspects of small and rural practices participation in legacy incentive programs and the Merit-based Incentive Payment System (MIPS). The GAO interviewed 23 stakeholders and CMS officials.


The GAO found that small practices did not perform as well as larger practices in the previous incentive programs. Medicare estimates that small practices will do better under MIPS because they believe the new system offers increased flexibility, such as allowing practices with 10 or fewer providers to participate as a virtual group that can work together and share resources with small practices in other areas of the country.


In contrast, stakeholders reported to the GAO that they believed that many small and rural practices would continue to face the same challenges in MIPS as these practices had with the legacy programs. Stakeholders suggested a number of actions CMS could take to help these practices including:

  • Providing timely information about program requirements
  • Increasing electronic health record functionality and standardization
  • Maintaining MIPS measures over time for continuity and testing measures to ensure a benefit to patient care
  • Minimizing changes to and complexity of MIPS
  • Making policy changes, such as allowing practices to opt-in to MIPS participation


The GAO report is available here.